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Protecting rights and facilitating stable relationships among federal agencies, labor organizations, and employees while advancing an effective and efficient government through the administration of the Federal Service Labor-Management Relations Statute.

This unfair labor practice case is before the Authority on exceptions
filed by the Respondent to the attached decision of the Administrative Law
Judge. No opposition was filed to the Respondent's exceptions.

The complaint alleges that Respondent violated section 7116(a)(1) and
(5) of the Federal Service Labor-Management Relations Statute (the Statute) by
unilaterally implementing a change in parking assignments without negotiating
with the Union over the substance and/or impact and implementation of the
change. The Judge concluded that the Respondent violated the Statute, as
alleged. The Judge recommended a statusquoante remedy,
which included reimbursing the parking fees paid by adversely affected unit
employees.

Pursuant to section 2423.29 of the Authority's Rules and Regulations
and section 7118 of the Statute, we have reviewed the rulings of the Judge made
at the hearing and find, as set forth fully below, that no prejudicial error
was committed. We affirm the rulings. Upon consideration of the Judge's
decision and the entire record, we adopt the Judge's findings, conclusions and
recommended Order only to the extent consistent with this decision.

II. Background and Judge's Decision

The Respondent operates three production shifts at its facility at 14th
and C Streets, Southwest, Washington, D.C.: (1) the day shift from 7 a.m. to 3
p.m.; (2) the evening shift from 3 p.m. to 11 p.m.; and (3) the midnight shift
from 11 p.m. to 7 a.m. The employees in the two bargaining units represented by
the Union are employed on each of the three shifts.

Prior to January 1990, the Respondent provided parking for eligible
employees at two locations. One parking area was located on the Respondent's
premises and was comprised of about 134 parking spaces. There was no charge to
employees assigned to this lot. The employees on the two late shifts were
accommodated as much as possible in this parking area because of the
unavailability of on-street parking when they reported to work. The second
parking area was located at a General Services Administration (GSA) parking lot
located off-site at 12th and C Streets, Southwest. There are about 96 assigned
spaces in the GSA lot. The employees assigned spaces in the GSA lot were
charged a $17.50 per month fee in accordance with applicable GSA
regulations.

Sometime in February 1989, the Respondent began developing projections
on the loss of parking spaces located at its facility due to planned
construction projects that were to commence in 1990. The Respondent requested
additional parking spaces for employee carpools at the GSA lot and executed a
purchase order for spaces at another lot located at Hogates' Restaurant at 9th
and Maine Avenue, Southwest, which is approximately a 15-minute walk from the
Respondent's facility. The Respondent decided to relocate virtually all day
shift employee carpools and vanpools to the off-site facilities.

The Respondent advised neither the Union nor the employees of its
decision to reassign day shift employee carpools and vanpools to off-site
facilities. Sometime on or about November 17, 1989, the Respondent issued its
bulletin for the 1990 Parking Open Season. The bulletin contained the usual
procedures for obtaining parking permits, and did not mention that free on-site
parking had been virtually eliminated for day shift employee carpools and
vanpools.

Sometime in early January 1990, without notice or bargaining with the
Union, the Respondent reassigned 84 day shift employee carpools and vanpools
from the free on-site location to the two off-site locations. Thus, while the
Respondent had allocated 92 spaces in 1989 for on-site day shift employee
carpools and vanpools, only 8 on-site spaces were allocated to those employees
in 1990. Unit employees who had been parking at the GSA lot for a fee were
bumped during this reassignment to the Hogates' Restaurant lot. On or about
January 17, 1990, when the Union learned of the reassignments, it demanded
bargaining. The Respondent ignored the Union's bargaining request. The change
in parking became effective on February 1, 1990. However, because the planned
construction had not begun, the Respondent notified employees on February 23,
1990, that it was temporarily reopening the free on-site parking for carpools
and vanpools. The Respondent made the availability of this temporary on-site
parking subject to the employee's carpool ranking, and those accepting a space
had no guarantee that an off-site space would be available once the on-site
parking was again closed. The Respondent implemented this subsequent offer of
temporary on-site parking without notice or bargaining with the Union.

The Respondent contended before the Judge that it did not change
established working conditions of unit employees with respect to the assignment
of employee parking. The Respondent asserted that the method of assigning
parking to employees did not change and that it followed the same practices in
assigning parking spaces in 1990 as it had utilized in prior years. The
Respondent contended that it was not required to negotiate over the substance
of the 1990 parking program because the Union had waived its right to negotiate
when it failed to request bargaining over a parking regulation issued in 1986.
The Respondent's assertion that the Union failed to request bargaining was not
contested by the Union. The Respondent offered into evidence a routing slip
dated April 1, 1986, that was attached to the proposed 1986 parking regulation.
This routing slip, which was from the Respondent's Labor Relations Officer and
addressed to all the unions at the facility, requested comments from such
unions by April 12, 1986, on the proposed regulation. Respondent Exhibit No.
16. The Respondent asserted that "virtually nothing changed" with the
implementation of the 1990 parking program. Judge's decision at 4.

The Judge found that "the issue here does not involve the mechanics of
how parking assignments to bargaining unit employees were made, but instead
involves the ripple effect the assignments from on-site parking to off-site
parking had on the conditions of employment of bargaining unit employees."
Id. The Judge noted that the Authority has consistently found that
parking constitutes a substantively negotiable condition of employment, and
that, where a substantively negotiable matter is involved, the deminimis standard does not apply.

The Judge rejected the Respondent's contention that virtually nothing
changed with the implementation of the 1990 parking program. Rather, the Judge
found that some employees who had parked free on-site for years were reassigned
to off-site parking locations that either required them to pay a monthly fee or
were a greater distance from the Respondent's facility, and that other
employees were required to move from the GSA lot to the Hogates' Restaurant
location, which was further away from the workplace and presented some safety
concerns.

The Judge noted that the Authority has found that an agency violates
section 7116(a)(1) and (5) of the Statute when it changes parking arrangements
without providing the exclusive representative with prior notice and the
opportunity to negotiate over the change. The Judge noted that the Respondent
did not deny that it gave no notice to the Union in this matter.

In response to the Respondent's argument that it was not required to
negotiate the substance of the 1990 parking program because the Union had
waived its rights to bargain over that matter when it failed to request
bargaining over a parking regulation the Respondent had implemented in 1986,
the Judge stated that, under Authority case law, waivers must be clear and
unmistakable and established either expressly or by bargaining history. The
Judge found that the Union's failure to request bargaining over the 1986
parking regulation was not a waiver by past practice. The Judge also found that
the language of the 1986 parking regulation did not waive the Union's right to
negotiate over the change in parking assignments. The Judge found that the
regulation does not address the issue of this case, which he defined as
"relocating parkers from on-site to off-site facilities due to construction."
Id. at 5. The Judge also found that the regulation does not mention or
otherwise limit the Union's bargaining rights over parking.

Accordingly, the Judge concluded that the Respondent's failure to
notify and negotiate with the Union concerning unilateral changes in the 1990
parking program was a violation of the Statute. The Judge recommended a
statusquoante remedy, including make-whole relief for
affected bargaining unit employees.

III. Respondent's Exceptions

The Respondent first contends that the Judge improperly excluded
evidence concerning the Union's bad faith in negotiations over the parking
program that occurred after the charge was filed. The Respondent maintains that
the excluded evidence was relevant and material as a possible defense and in
mitigation of the alleged unfair labor practice. The Respondent cites the
Authority decision in Action, 26 FLRA 299 (1987), in support of its
position. The Respondent argues that in Action the Authority ruled that
the subsequent execution of a collective bargaining agreement by the parties
does not affect the General Counsel's primafacie case regarding
an earlier refusal to bargain. The Respondent notes that the Authority found
that "the terms and execution of the subsequent collective bargaining agreement
could be raised by the respondent in response to the primafacie
case as a defense or in mitigation." Exceptions at 8.

Next, the Respondent contends that the Judge improperly concluded that
the Respondent changed established working conditions of bargaining unit
employees when it assigned parking under the 1990 parking program. The
Respondent contends that the principal inquiry regarding the issue of change in
the parking program involves the methodology of assigning parking to Respondent
employees. It argues that the same methodology has been used since 1986.

The Respondent further contends that the Judge improperly concluded
that the Union did not waive its right to bargain over the substance of the
1990 parking program. The Respondent notes that the Authority has held that a
waiver of bargaining rights, whether by express agreement, bargaining history
or inaction, is a legitimate defense to a charge of refusal to bargain. It
argues that the facts reflect that: (1) in 1986 the Union was notified of
management's decision to change the then-existing parking regulation; (2) the
Union did not request bargaining over this new regulation, which, the
Respondent contends, contains language giving the Respondent the right to
cancel any parking spaces without notice because of Agency requirements,
including construction and modernization, without requiring the Respondent to
provide alternative parking to carpools displaced by such cancellations; and
(3) the Union did not request bargaining over employee parking for the next
three years, during which time bargaining unit employees were denied on-site
parking and issued parking at the GSA lot. Accordingly, the Respondent contends
that it is clear that the Union waived its right to bargain regarding changes
in the assignment of parking.

Finally, the Respondent contends that the Judge improperly ordered a
statusquoante remedy as relief for the alleged unfair
labor practice and that his order of monetary relief is also inappropriate. The
Respondent asserts that special circumstances exist that make a statusquoante remedy not warranted or appropriate. The Respondent
argues that a return to the statusquo would disrupt and impair
the effective conduct of its operation because permanent construction has taken
place that has eliminated certain on-site employee parking. It claims that
although some parking may be returned at a later date, approximately 50 to 60
percent of the parking has been permanently lost. The Respondent also argues
that re-allocating parking from the evening and midnight shift employees to
afford on-site parking for day shift parking would also be disruptive to its
operations because the availability of on-site parking for evening and midnight
shift employees is necessary to continued efficient Agency operations. The
Respondent notes that there is an absence of adequate off-site parking and a
lack of public transportation after hours for the employees on these two
shifts. The Respondent also contends that any restoration of parking for the
bargaining unit employees represented by the Union would adversely affect and
be disruptive to existing relations between it and other labor organizations
representing other bargaining units of its employees.

The Respondent maintains that it would be inappropriate to award the
reimbursement of parking fees to unit employees. The Respondent notes that an
employee must mitigate damages and limit the Government's liability. It
contends that the evidence reflects that bargaining unit employees failed to
mitigate their damages.

IV. Analysis and Conclusions

A. No Prejudicial Error was Committed by the Judge by Excluding
Evidence of Post-Charge Conduct

We find that the Judge did not commit prejudicial error by excluding
evidence of post-charge conduct. The Respondent contends that the excluded
evidence would show that the Respondent attempted to negotiate with the Union
concerning the 1990 parking program three months after the charge was filed but
that the Union refused to negotiate, thus displaying the Union's bad faith. The
Respondent maintains that this alleged bad faith was relevant and material to
its defense.

The Authority has found that an agency's belated offers to bargain
concerning a change in working conditions, especially where there was no
advance notice to the union of the change, does not satisfy the agency's
obligation to bargain under the Statute. Air Force Accounting and Finance
Center, Denver, Colorado, 42 FLRA 1196, 1207 (1991). Further, the Authority
has found that a union is under no obligation to respond to such belated offers
to bargain. Id. In sum, events that take place after a unilateral
implementation of a change in conditions of employment are irrelevant to a
determination of whether a violation of the Statute resulted from the
unilateral action. SeeU.S. Department of Transportation and Federal
Aviation Administration, 40 FLRA 690, 705 (1991) petition for review
filed sub nom.Professional Airways Systems Specialists Division,
District No. 1-MEBA/NMU, AFL-CIO v. FLRA, No. 91-1310 (D.C. Cir. June 23,
1991).

We reject the Respondent's reliance on Action to argue that the
Judge should have considered the evidence "as a defense or in mitigation."
Exceptions at 8. In that case, which involved the respondent's alleged unlawful
refusal to bargain over travel and per diem in response to the union's demand,
there was no objection made to the introduction of a subsequent bargaining
agreement between the parties that contained a zipper clause but did not
mention travel and per diem. Indeed, it was the General Counsel who had
submitted the bargaining agreement into evidence. Thus, in contrast to this
case, there was no issue before the Authority in Action concerning the
admissibility of the evidence. Moreover, although in Action it was at
least arguable that the express terms of the subsequent bargaining agreement,
which was retroactive to a date one month after the alleged refusal to bargain,
could serve to mitigate any remedy imposed on the respondent, no such argument
is available to the Respondent in this case.

Accordingly, we find that the exclusion of evidence concerning events
that occurred months after the alleged violation and the filing of the charge
in this case are not relevant or material to our determination of whether the
Respondent violated the Statute when it unilaterally, and without notice to the
Union, changed its parking program.

B. The Union Waived Its Right to Bargain over the Respondent's
Decision to Change Parking Assignments

Initially, we note, as did the Judge, that the Authority consistently
has found that the provision of parking for employees is a negotiable condition
of employment. See, for example, United States Immigration and
Naturalization Service, 43 FLRA 3 (1991) (INS), petition for
review filed sub nom. United States Department of Justice, Immigration
and Naturalization Service v. FLRA, No. 91-4210 (2d Cir. Dec. 26, 1991) We
disagree with the Respondent's contention that it did not change its parking
program when it eliminated free on-site parking spaces at its facility. Thus,
we conclude that the abrupt reassignment of parking spaces went beyond the
established "methodology of assigning parking," as the Respondent asserts.
Exceptions at 10. However, we further conclude that the Union waived its right
to bargain over that change.

A waiver of a union's statutory right to bargain must be clear and
unmistakable. U.S. Department of the Treasury, Customs Service, Washington,
D.C. and Customs Service, Northeast Region, Boston, Massachusetts, 38 FLRA
770, 784 (1990). A union can waive its right to bargain by failing to request
bargaining when an agency has given it sufficient notice of a proposed change
in a condition of employment. See, for example, U.S.
Immigration and Naturalization Service, 24 FLRA 786, 790-91 (1986) (agency
satisfied its bargaining obligation when it implemented revised procedures
after providing notice and an opportunity to union to submit bargaining
proposals, but union failed to act). Here, there is no question that the
Respondent's 1986 parking regulation, over which the Union failed to exercise
its right to request bargaining, set forth the requirements and procedures for
assigning employee parking at the Respondent's facility. Specifically, as
relevant here, the regulation provides at paragraph 5-12-4f:

Liability. Since parking in Bureau controlled parking areas is granted
as a privilege rather than as a right, those who accept this parking privilege,
do so at their own risk. The Bureau maintains the right to cancel any space(s)
without notice and has no obligation to provide alternate parking. . .
.

Respondent Exhibit No. 4. Further, paragraph 5-12-5c states:

Assignment Period. The assignment of parking spaces is made for a
period of one year, beginning on the first working day in January concurrent
with the return from year-end shutdown (YES). Exceptions will be made as Bureau
construction/modernization requirements or other circumstances
dictate.

Id. Based on this language, we find that the decision by the
Respondent to eliminate employee parking spaces because of construction at its
facility without notifying or bargaining with the Union is permitted by the
regulation, which reserves to management the right to eliminate any parking
spaces because of agency requirements. Moreover, although parking assignments
are generally made for a year, there is a specific exception to that policy
where construction and modernization require the elimination of parking. The
Union could have bargained over these matters when the Respondent promulgated
its parking regulation in 1986, but it chose not to do so. By its inaction at
that time, the Union waived its right to object when the Respondent exercised
its right to implement its new parking policy. CompareAir Force
Accounting and Finance Center, Lowry Air Force Base, Denver, Colorado, 42
FLRA 1226, 1239-40 (1991) (union did not waive its right to bargain over impact
and implementation of agency's decision to adjust employee arrival and
departure times where nothing in agency regulation, over which union failed to
bargain, demonstrated a waiver of union's right to be notified about or to
bargain over the matter). Consequently, we conclude that the Respondent did not
have to negotiate with the Union over its decision to eliminate parking for
bargaining unit employees represented by the Union.

C. The Union Did Not Waive Its Right to Bargain over the Impact and
Implementation of the Respondent's Decision

We find that the Union did not clearly and unmistakably waive its right
to bargain over matters concerning the impact and implementation of the change
in parking arrangements that were not covered by the 1986 regulation. When a
union waives its right to bargain over the substance of a management decision
to change a condition of employment it does not necessarily waive its right to
bargain concerning the impact or implementation of that decision. SeeU.S. Department of Labor, Occupational Safety and Health Administration,
Chicago, Illinois, 19 FLRA 454 (1985) (under the parties' agreement union
waived certain rights to bargain over the decision to change the manner in
which government-owned vehicles would be assigned, but did not clearly and
unmistakably waive its right to bargain over procedures and appropriate
arrangements); Department of the Air Force, Headquarters, Air Force
Logistics Command, Wright-Patterson Air Force Base, Ohio, 22 FLRA 502,
504-05 (1986) (union waived its right to bargain over the substance of the
change in policy by agreeing to the terms of the parties' agreement, but there
was no clear and unmistakable waiver of union's right to bargain over the
procedures that the agency would observe in exercising its authority with
regard to the change). SeealsoChallenge-Cook Brothers,
282 NLRB 21 (1986), enf'd 843 F.2d 230 (6th Cir. 1988) (union waived its
right to bargain over the employer's decision to make unilateral transfers of
work from one plant to another when it agreed to the management's right clause
in the parties' collective bargaining agreement but, as that clause was
completely silent with respect to the effects of a relocation decision, union
did not relinquish its right to bargain over the effects of the employer's
unilateral acts).

Here, we find that the Respondent's 1986 parking regulation does not
address the full range of impact and implementation issues stemming from
management's decision to eliminate parking spaces when Agency requirements
necessitate such action. We recognize that under the regulation the Respondent
was not obligated to provide "alternate parking" to displaced carpools and
vanpools. Nevertheless, when the Respondent decided to provide alternative
parking that decision raised a number of impact and implementation issues that
are not covered by the regulation. Accordingly, we find that if this change in
parking arrangements had more than a deminimis effect on the
bargaining unit, the Respondent was obligated to engage in impact and
implementation bargaining when, after it eliminated virtually all free on-site
parking for day shift employee carpools and vanpools, it provided alternative
parking for those employees who were displaced by its actions and subsequently
reinstated temporary free on-site parking. See, generally,
Department of Health and Human Services, Social Security Administration,
24 FLRA 403 (1986) (SSA) (an agency must bargain concerning the impact
and implementation of a change that has more than a deminimis
impact on unit employees).

To determine whether a change has more than a deminimis
impact on unit employees, the Authority examines the record to determine the
extent of the effect or reasonably foreseeable effect of the change on
conditions of employment. SSA, 24 FLRA at 407-08. Applying that standard
to this case, we find that the Respondent's change in its parking arrangements
had more than a deminimis impact on employees' conditions of
employment. The record shows that the free on-site parking is in a secured area
and that employees have a relatively easy access to their vehicles if
circumstances required them to leave the worksite during their shift. The
alternative parking at the Hogates' Restaurant lot was not secured, except for
a parking attendant. Further, the record shows that the Hogates' lot was .7 of
a mile from the Respondent's facility, a 15-minute walk. At the hearing, the
Union President testified that parking at the Hogates' Restaurant lot raises
concerns regarding security at the lot for vehicles and employees, and of
dangers associated with the walk from the lot to the worksite, particularly
when it is dark outside. Further, the Respondent's subsequent offer to
employees of temporary on-site parking left the employees who accepted the
offer with the possibility of having no parking available to them once they
were again displaced. Thus, the changes had more than a deminimis effect on the employees. Consequently, the Union had a right to
present proposals addressing the impact and implementation of the changes.

Accordingly, we find that the Respondent violated section 7116(a)(1)
and (5) of the Statute when it unilaterally implemented changes in its parking
arrangements without first notifying the Union and affording the Union an
opportunity to bargain concerning procedures and appropriate arrangements for
unit employees adversely affected by such changes in parking arrangements.

D. Remedy

We find that a statusquoante remedy is not
warranted or appropriate in the circumstances of this case. Further, we find
that bargaining unit employees should not be reimbursed for parking fees paid
as a result of the changes.

In Federal Correctional Institution, 8 FLRA 604 (1982)
(FCI) the Authority set forth factors to be considered in each case to
determine whether a statusquoante remedy is warranted
for a refusal or failure to bargain over procedures and appropriate
arrangements that management will observe in exercising its rights under the
Statute. Under the FCI criteria, the Authority considers, among other
things: (1) whether, and when, notice was given to the union by the agency; (2)
whether, and when, the union requested bargaining; (3) the willfulness of the
agency's conduct in failing to discharge its bargaining obligations under the
Statute; (4) the nature and extent of the impact experienced by adversely
affected employees; and (5) whether, and to what degree, a statusquoante remedy would disrupt or impair the efficiency and
effectiveness of the agency's operations. Id. at 606.

Here, the Respondent failed to give the Union notice that, due to
construction at its facility, it was virtually eliminating free on-site parking
for day shift employee carpools and vanpools even though its planning for the
elimination of those spaces began well in advance of the implementation date.
The Union demanded bargaining as soon as it learned of the reassignment of day
shift employee carpools and vanpools to the two off-site locations. However,
the effects on employees who were adversely affected, although not deminimis, were not severe. In contrast, a statusquoante remedy would place a distinct burden on the efficiency of the
Respondent's operations.

In order to restore the on-site parking for use by bargaining unit
employees as it existed prior to February 1, 1990, the Respondent would have to
arrange either to reinstate the eliminated spaces or bump other employees from
those remaining spaces. The record reflects that the spaces could not be
reinstated without disrupting the construction that is in progress. In
addition, the Respondent contends that the construction will permanently
eliminate approximately 50 to 60 percent of the on-site parking, thus making it
impractical to reinstitute parking for bargaining unit employees without
modifying the construction plans or, if construction has been completed, by
removing the new construction. Further, it appears that there is a real concern
about having available on-site parking for employees on the evening and
midnight shifts. Because the Respondent's operation requires overlapping
shifts, the record reflects that employees on the late shifts have only limited
alternative parking available. The parking at the GSA lot, for example, would
be occupied by the day shift employees when the evening shift employees begin
arriving at 2:00 p.m. and conversely, must be vacant when the day shift
employees arrive in the morning. Also, the Hogates' Restaurant lot was not
available to the Respondent at those off-hours and on-street parking was
limited. The on-site parking was the only alternative for the late shifts
because vehicles in that lot could be easily moved to accommodate the shifts.
Finally, public transportation after the evening rush hour and before the
morning rush hour is extremely limited. Accordingly, we find that to displace
those late shift employees from on-site parking would impair the efficiency and
effectiveness of the Respondent's 24-hour operation.

In view of the impracticality and disruption that would be caused by
requiring the Respondent to return to the parking arrangements that existed
prior to February 1, 1990, we conclude that, on balance, a statusquoante remedy is not appropriate. CompareINS, 43
FLRA at 9-10 (Authority found that a statusquoante
remedy was appropriate where the agency was required to bargain over the
substance of the disputed change in parking and no special circumstances were
present).

We also find that monetary reimbursement to bargaining unit employees
who were displaced by the elimination of free on-site parking is not warranted
in the circumstances of this case. The record shows that there was no change in
the procedures used by the Respondent in ranking and selecting employees for
spaces in the free on-site lot or at the GSA lot and that, prior to the change,
bargaining unit employees were assigned to the GSA lot. Thus, any additional
charges incurred by employees for parking in the GSA lot did not arise from the
Respondent's failure to bargain over the impact and implementation of its
decision to reassign parking. Rather, they were the direct result of the
elimination of on-site parking, which, as we found above, did not give rise to
a bargaining obligation.

Accordingly, we find that a cease and desist order, accompanied by a
prospective bargaining order, will effectuate the purposes and policies of the
Statute.

V. Order

Pursuant to section 2423.29 of the Authority's Rules and Regulations
and section 7118 of the Statute, the Bureau of Engraving and Printing,
Washington, D.C. shall:

1. Cease and desist from:

(a) Unilaterally implementing changes in the working conditions of
bargaining unit employees by changing employee parking arrangements in 1990
without first notifying the International Association of Machinists and
Aerospace Workers, Lodge 2135, AFL-CIO, the exclusive bargaining representative
of certain of its employees, and affording such bargaining representative an
opportunity to bargain concerning procedures and appropriate arrangements for
unit employees adversely affected by the changes in parking arrangements.

(b) In any like or related manner, interfering with, restraining, or
coercing its employees in the exercise of their rights assured by the
Statute.

2. Take the following affirmative action in order to effectuate the
purposes and policies of the Statute:

(a) Notify and, upon request, negotiate in good faith with the
International Association of Machinists and Aerospace Workers, Lodge 2135,
AFL-CIO, the exclusive bargaining representative of certain of its employees,
concerning procedures and appropriate arrangements for unit employees adversely
affected by changes in parking arrangements.

(b) Post at its facilities copies of the attached Notice on forms to be
furnished by the Federal Labor Relations Authority. Upon receipt of such forms,
they shall be signed by the Director of the Bureau of Engraving and Printing,
Washington, D.C., and shall be posted and maintained by him for 60 consecutive
days thereafter, in conspicuous places, including all bulletin boards and other
places where notices to employees are customarily posted. Reasonable steps
shall be taken to insure that such notices are not altered, defaced, or covered
by any other material.

(c) Pursuant to section 2423.30 of the Authority's Rules and
Regulations, notify the Regional Director, Washington, D.C. Region, Federal
Labor Relations Authority, in writing, within 30 days from the date of this
Order, as to what steps have been taken to comply.

NOTICE TO ALL EMPLOYEES

AS ORDERED BY THE FEDERAL LABOR RELATIONS AUTHORITY

AND TO EFFECTUATE THE POLICIES OF THE

FEDERAL SERVICE LABOR-MANAGEMENT RELATIONS STATUTE

WE NOTIFY OUR EMPLOYEES THAT:

WE WILL NOT unilaterally implement changes in the working conditions of
bargaining unit employees by changing employee parking arrangements in 1990
without first notifying the International Association of Machinists and
Aerospace Workers, Lodge 2135, AFL-CIO, the exclusive bargaining representative
of certain of our employees, and affording such bargaining representative an
opportunity to bargain concerning procedures and appropriate arrangements for
unit employees adversely affected by the changes in parking arrangements.

WE WILL NOT, in any like or related manner, interfere with, restrain, or
coerce our employees in the exercise of their rights assured by the Federal
Service Labor-Management Relations Statute.

WE WILL notify and, upon request, negotiate in good faith with the
International Association of Machinists and Aerospace Workers, Lodge 2135,
AFL-CIO, the exclusive bargaining representative of certain of our employees,
concerning procedures and appropriate arrangements for unit employees adversely
affected by changes in parking arrangements.

_______________________(Activity)

Dated:______ By:_____________________

(Signature) (Title)

This Notice must remain posted for 60 consecutive days from the date of
posting, and must not be altered, defaced, or covered by any other
material.